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Part 2 - Initial Questions
2.1 In addition to the specific questions included throughout the consultation document, we would like your views on the overarching questions set out below.
2.2 You will probably find it helpful to read the explanation of the content of the proposed Directive and our explanation of existing EC and domestic legislation which is in the following sections before you do so. Where possible please provide explanation and examples to support comments made.
2.3 Questions:
- A. What are your views on the current level of soil protection measures in the UK considering the risks and threats faced by soils, including those identified by the Commission?
- B. If you consider these measures to be inadequate, do you believe that any gaps are best dealt with on a common basis across the EU, for example to avoid distortion in competition, or better dealt with at a domestic level?
- C. What, if any, gaps exist in terms of addressing soil protection at an EU level in particular the risks identified by the Commission?
- D. Does the solution to these gaps lie in amending existing EU Directives, or in introducing a new overarching framework for soil protection?
- E. Are there any existing EU provisions that give some protection to soils which, in your view, do not work or which could do with simplification?
- F. In terms of the risks and threats identified by the Commission, how urgent are these problems? Is there sufficient evidence to tackle them now?
- G. Who should bear the costs involved in any new obligations? Should we follow a polluter pays approach, a market-based system where, for example, a property developer pays the cost of remediation, or should these costs fall to taxpayers?
2.4 This consultation closes on 19 October 2007 but we would welcome early comments if possible in view of the Portuguese Presidency's intention to discuss this proposal at the October Environment Council (30 October 2007).
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